LHC Group’s Corporate Compliance and Ethics Program was developed to help ensure that we conduct our business in compliance with all applicable federal and state laws, rules and regulations and to reduce the risk of misconduct. According to the Office of the Inspector General (OIG) as described in the Federal Sentencing Guidelines, a well-built compliance program should have a strong foundation that includes the following seven elements:

1. Written Policies, Procedures and Standards of Conduct;
2. Designated Compliance Officer and Compliance Committee;
3. Effective Training and Education;
4. Reporting and Investigating: Effective Lines of Communication;
5. Enforcement and Discipline: Well-Publicized Disciplinary Guidelines;
6. Strong Internal Monitoring and Auditing Program; and
7. Response and Prevention: Prompt Response to Detected Offenses.

We have developed active processes tailored to our focus on particular risk areas that are common throughout the industries in which we operate. These voluntary guidelines identify areas to improve and enhance our internal controls so that billing practices and other business arrangements are in compliance with Medicare, Medicaid and all other applicable rules and regulations. To follow the OIG guidelines, we have developed a Corporate Compliance and Ethics Program that consists of the following elements:

1. Development, distribution and routine review and update of the Code of Conduct and Ethics and policies and procedures which promote LHC Group’s commitment to compliance and ethics, and address specific areas of risk to the organization.
2. Designation of a Chief Compliance Officer who is responsible for overseeing and monitoring the Corporate Compliance and Ethics Program, and a Corporate Compliance Committee who advises the Chief Compliance Officer and assists in the execution of the Corporate Compliance and Ethics Program.
3. Regular and effective training and education, which addresses the various components of the Corporate Compliance and Ethics Program and effectively communicates LHC Group’s standards and procedures.
4. Development of an anonymous third-party compliance hotline and website, the IntegrityLine, for employees to communicate with the Chief Compliance Officer to report potential violations or ask questions.
5. A system to respond to allegations of improper activities, and to consistently enforce appropriate disciplinary action for non-compliance.
6. Performance of regular compliance audits and evaluation techniques, internally and externally, to monitor compliance with relevant healthcare standards and regulations.
7. Immediate response to and the investigation of possible violations of the Code of Conduct and Ethics, Compliance policies and procedures and applicable laws, rules or regulations, as well as appropriate corrective action initiatives and consistent discipline for any violations that have occurred.

In addition, we have also established extensive policies and guidelines anchored around privacy and security and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) for our patients, employees and business associates.

HIPAA

LHC Group is committed to maintaining the confidentiality, privacy and security of its patients’ protected health.